Overview
- Headquarters
- Owings Mills, MD
- Average Client Assets
- $4.2 million
- Minimum Account Size
- $100,000
- SEC CRD Number
- 120141
Fee Structure
Primary Fee Schedule (2026 ADV)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $2,000,000 | 1.00% |
| $2,000,001 | $5,000,000 | 0.85% |
| $5,000,001 | $10,000,000 | 0.75% |
| $10,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $45,500 | 0.91% |
| $10 million | $83,000 | 0.83% |
| $50 million | $283,000 | 0.57% |
| $100 million | $533,000 | 0.53% |
Clients
- HNW Share of Firm Assets
- 68.97%
- Total Client Accounts
- 1,475
- Discretionary Accounts
- 1,469
- Non-Discretionary Accounts
- 6
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting
Regulatory Filings
Additional Brochure: 2026 ADV (2026-03-16)
View Document Text
Glass Jacobson Investment Advisors, LLC
10055 Red Run Blvd Suite 160
Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
Part 2A of Form ADV: Firm Brochure
This brochure provides information about the qualifications and business practices of Glass Jacobson
Investment Advisors, LLC, d/b/a Glass Jacobson Wealth Advisors (“Glass Jacobson” or the “Company”). If you
have any questions about the contents of this brochure, please contact us at 443-384-6888 or by mail to the
above-listed address. The information contained in this brochure has not been approved or verified by the
United States Securities and Exchange Commission (“SEC”) or by any state securities regulatory authority.
Glass Jacobson is registered as an investment adviser with the SEC. The firm’s registration does not imply a
certain level of skill or training.
www.adviserinfo.sec.gov
Additional information about Glass Jacobson is available at
.
The information included in this brochure is intended to provide you with useful information to evaluate our services and
enable you to compare our services with those of other advisory firms.
ITEM 2. MATERIAL CHANGES
This Brochure dated March 11, 2026 contains material changes since our last annual Brochure update on
January 2, 2026
We have updated the following Items in this filing:
Item 4, Item 5, Item 7, Item 10, Item 12, Item 13, Item 14, and Item 18.
Please review our updated discussion.
Mercer Global Advisors Inc. has entered into an agreement to acquire Glass Jacobson Investment Advisors, LLC. The
transaction closed on November 30, 2025, and resulted in a change of ownership. Mercer Global Advisors Inc. owns
one hundred (100%) percent of the operating assets of Glass Jacobson Investment Advisors, LLC. Due to the
acquisition of Glass Jacobson Investment Advisors, LLC, the firm has provided notice to affected clients of the
assignment to Mercer Global Advisors Inc. (a SEC-registered investment advisor) of such clients’ advisory
arrangements with Glass Jacobson Investment Advisors, LLC to the extent required under applicable law. Once the
account transfer process is complete at the custodial level, Glass Jacobson Investment Advisors, LLC will file a Form
ADV-W to terminate its registration with the SEC and wind down its advisory business.
Copies of Mercer Global Advisors’ ADV Part 2A, Form CRS and Privacy Notice are available upon request by calling
888.885.8101 or at www.merceradvisor.com.
Additionally, effective January 1, 2026, our Chief Compliance Officer has changed from Avrahm Levitan to Jonathan
Dinkins.
ITEM 3. TABLE OF CONTENTS
Clients may request a copy of this Form ADV Part 2A at any time without charge by sending a written request
to our Chief Compliance Officer at our address or by e-mail to srdinkins@gjwadvisors.com.
Item 4. Advisory Business
Item 5. Fees and Compensation
Item 6. Performance-Based Fees and Side-By-Side Management
Item 7. Types of Clients
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Item 9. Disciplinary Information
Item 10. Other Financial Industry Activities and Affiliations
Item 11. Code of Ethics
Item 12. Brokerage Practices
Item 13. Review of Accounts
Item 14. Client Referrals and Other Compensation
Item 15. Custody
Item 16. Investment Discretion
Item 17. Voting Client Securities
Item 18. Financial Information
Item 19. Requirements for State-Registered Advisers
Pg. 3
Pg. 6
Pg. 9
Pg. 9
Pg. 9
Pg. 11
Pg. 11
Pg. 12
Pg. 12
Pg. 16
Pg. 17
Pg. 17
Pg. 17
Pg. 18
Pg. 18
Pg. 18
ITEM 4. ADVISORY BUSINESS
DESCRIPTION AND HISTORY OF ADVISORY BUSINESS:
The Company offers a proactive, integrated approach to financial services. Our integrated services include
divorce & litigation support, investment advisory services, financial planning, and ERISA retirement plan
services. Bringing these services together allows our clients to see their personal finances in the entirety
and make better decisions for business and life.
Messrs. Edward Jacobson, Michael Cohen and Jonathan Dinkins, Sr. are Managing Members of the Company.
The Company has been an investment advisor since 2001.
Mercer Global Advisors Inc. has entered into an agreement to acquire Glass Jacobson Investment Advisors,
LLC. The transaction closed on November 30, 2025, and resulted in a change of ownership. Mercer Global
Advisors Inc. owns one hundred (100%) percent of the operating assets of Glass Jacobson Investment
Advisors, LLC. Due to the acquisition of Glass Jacobson Investment Advisors, LLC, the firm has provided
notice to affected clients of the assignment to Mercer Global Advisors Inc. (a SEC-registered investment
advisor) of such clients’ advisory arrangements with Glass Jacobson Investment Advisors, LLC to the extent
required under applicable law. Once the account transfer process is complete at the custodial level, Glass
Jacobson Investment Advisors, LLC will file a Form ADV-W to wind down the advisory business.
Copies of Mercer Global Advisors’ ADV Part 2A, Form CRS and Privacy Notice are available upon request by
calling 888.885.8101 or at www.merceradvisors.com.
GENERAL INFORMATION ABOUT THE COMPANY AND ITS SERVICES
Although the Company’s advice is not limited to such investments, The Company’s investment advice
primarily relates to mutual funds and certain investment products. The Company’s investment
adviser representatives constitute the Company’s investment committee that determines general
investment solutions suitable for client use.
The committee meets quarterly and reviews its investment solutions. The criteria which the committee uses
to review these solutions includes but is not limited to, historical performance, fees, manager tenure,
investment risk metrics, securities composition, style, appropriate benchmarks, and industry indices.
The Company offers:
1)
2)
3)
4)
Discretionary or Non-Discretionary Investment Advisory Services.
Financial Planning Services.
Retirement Plan Consulting Services
Administrative Services
Our Current clients include individuals; high net worth individuals; 401(k), defined contribution, and defined
benefit pension plans; trusts; estates; and charitable organizations.
Following is a discussion of our services:
Discretionary or Non-Discretionary Investment Advisory Services
Regardless of how an account is managed, the Company tailors’ advisory services to the individual needs of
its clients, by diversifying and managing each client’s portfolio in line with the client’s pre-defined investment
objectives, risk tolerance, time horizon, financial information, and other various suitability factors that are
identified. Such factors include restrictions the client may impose on investing in certain securities or types of
securities. However, restrictions and other guidelines imposed by clients on the management of their
accounts may affect the composition and performance of a client’s portfolio. Therefore, performance of the
portfolio may not be identical with accounts of other clients with similar investment objectives and managed
by the same investment adviser representative.
3
Stemming from our holistic approach to service, client accounts are usually managed on a household basis.
The discretionary managed account is designed to permit the Company to make investment decisions for the
account pursuant to investment objectives chosen by the client. Rarely will The Company manage an
advisory account on a non-discretionary basis.
Generally, The Company requires that clients establish brokerage accounts with Schwab Institutional
(“Schwab”), a division of Charles Schwab & Co., Inc., or Fidelity Registered Investment Advisor Group
(“Fidelity”), a division of Fidelity Investments, to maintain custody of such clients. The Company
maintains a relationship with Schwab, and Fidelity which enables clients to receive institutional
trading and operations services to which the average retail client would not otherwise have access. All
transactions are cleared through Schwab, or Fidelity.
Clients may also choose to maintain a brokerage relationship with one or more custodians other than
Schwab, or Fidelity and in connection therewith participate in the custodial integrator By All Accounts, Inc.
(“BAA”) service provided by the Company. The BAA service consolidates information about client
investments held with other custodians. Clients may participate in the BAA service in one or both of the
following ways:
First, clients may choose to participate in the BAA service in which the Company can trade in subaccounts
of clients’ variable annuities.
Second, clients may choose to participate in the BAA service where the Company does not trade and
manage the client’s account. Rather, such participation enables the Company to consider information about
the client’s investments held with other custodians when rendering advice with respect to the Investment
Advisory Account, as well as to provide non-discretionary advice to such client as to the investments in the
accounts reported through BAA. Such clients are under no obligation to act on or consider any advice that
may be rendered by the Company with respect to such accounts, and clients may direct the investments in
such accounts in any manner they desire. With respect to any accounts reported through BAA that are not
included in the Investment Advisory relationship, the Company has no responsibility to direct investments
in, and/or place trades for such accounts.
In both scenarios clients are charged the annual fee payable quarterly in advance. The value of such
accounts is included in the overall value of the Investment Advisory Account for purposes of calculating the
Company’s Management Fee.
Also, the Company offers an investment advisory service to Clients that have assets in a qualified plan,
including but not limited to a 401(k) plan or 403(b) plan. Such plans are considered “held-away” from GJIA,
i.e., the assets in these plans are not administered by Charles Schwab or Fidelity, the custodians GJIA utilizes
for Clients that have an Advisory Account with GJIA. Rather, the “held-away” assets are administered by a
custodian selected by the Client. For Clients with “held-away” assets, GJIA contracts with Pontera Solutions,
Inc., a third-party order management platform, to provide the following investment advisory services to
Clients that have “held-away” assets: review of the current holdings and investment options in the “held-
away” account; implement the Client’s investment strategies in the “held-away” account; monitor the
investments in the “held-away” account; and perform, as necessary, asset allocation and rebalancing in the
“held-away” account. Clients with a held-away account may or may not have an Advisory Account with GJIA.
Clients with mutual funds and/or variable annuity sub-accounts in their portfolios are effectively paying
the Company and the mutual fund/variable annuity advisor for the management of the client’s assets. Such
clients therefore are subject to both the Company’s management fee and the management fee of the mutual
fund. For variable annuities, such management fees include both fees to the manager of the variable
annuity sub-account and fees to the insurance company (Mortality and Administrative). For example,
client who offers a 401(k)-retirement plan to their employees knows that the plan participants pay the
mutual fund management fees in addition to other applicable costs.
4
Financial Planning Services
The Company offers the following financial planning services to its clients:
Personal Financial Analysis
Insurance and Estate
Capital Needs Analysis
Cash Flow Retirement
Investment Analysis
Education
Financial planning information is obtained through personal interviews with the client concerning the client’s
current financial status, future goals and attitudes towards risk. Related documents supplied by the client
are carefully reviewed, along with data gathered from the client. Typically, a written report is delivered.
Retirement Plan Consulting Services
The Company offers retirement plan consulting services for ERISA and Non-ERISA covered plans. The
Company uses various internet-based 401(k) daily valuation retirement plan platforms, to deliver its
401(k) services to businesses across the United States. The platforms allow a company to offer its employees
the widest possible array of investment options using daily valuation connectivity and multi-fund/multi-
family investments.
In connection with providing these platforms, the Company will enter into its agreement with the
Responsible Plan Fiduciary and such plan’s trustee(s) to provide discretionary and non-discretionary
investment advice for the 401(k) plan. The decision whether to implement or act upon the Company’s
recommendations or advice rests solely with the Responsible Plan Fiduciary.
The services provided by the Company to such plan typically include the following:
A)
B)
Assist in the development of an Investment Policy Statement, which establishes the investment
policies and objectives for the plan.
Assist in the search for and selection of mutual funds.
C)
Evaluate plan costs, mutual fund performance and risk.
D)
Monitor the suitability of all selected investment options and recommend changes when appropriate.
E)
F)
Provide assistance to plan fiduciary(ies) regarding ongoing supervision and due diligence of
mutual funds’ performance and risk metrics.
Assist the plan fiduciary(ies) in evaluating how to avoid or manage conflicts of interest; and
When engaged to do so, the Company may assist in the education of the plan participants about general
investing principles and the investment alternatives available under the plan. The education
component will customarily be delivered through group meeting, one-on-one counseling, or a
proprietary interactive video workshop designed to provide investment education for participants of
company sponsored 401(k) plans. A participant may access the website by registering as a user and
accepting terms of use. The participant will then be guided through a series of videos that describe the
advantages of joining the company plan, saving for retirement, and general principles of investing. Each
participant has the opportunity to take a risk questionnaire to assess their risk tolerance. Participants are
then guided to potential suitable investment allocation solutions provided by the Company plan (the
mutual fund lineup).
Only if a participant engages the Company as an Investment Advisor, will we provide individualized advice
regarding their investments in the company plan.
Administrative Services
In addition to the investment advisory services described above, The Company provides administrative
services to one or more of its clients. These arrangements require the execution of a separate agreement with
the Company.
5
WRAP FEE PROGRAM
The Company does not sponsor or manage any wrap fee programs.
AUM
The Company manages client assets on a discretionary and a non-discretionary basis, As of December 31,
2025, The Company’s regulatory assets under management was $928 million. The complete transfer to
Mercer is still in process.
ITEM 5. FEES AND COMPENSATION
COMPENSATION
Discretionary or Non-Discretionary Investment Advisory Management Fee
The Company's Management Fee with respect to Investment Advisory Accounts is based upon a percentage of
the portfolio value on the last day of the prior quarter and is billed in advance at the beginning of each quarter.
Adjustments for significant contributions and withdrawals to the portfolio are prorated for the quarter in
which the change occurs.
If an Investment Advisory Account is opened during the quarter, the Management Fee will be prorated for the
entire quarter and based on the beginning account value. The account will be charged two fees during the first
billing cycle to reflect the partial quarter when the account was opened (payment in arrears) and the current
quarter (billing in advance).
For Investment Advisory Accounts, including types of accounts serviced through the firm’s Investment
Advisory services platform for Individuals, Trust’s, Estates, Foundations, and Pooled Retirement accounts (e.g.
Cash Benefit Pension, Defined Benefit Pension, and Solo 401(k)), the Management Fee is charged according to the
following tiered fee schedule:
For account relationships of $1 million or more:
PORTFOLIO VALUE
First $2,000,000 of assets
Next $3,000,000 of assets
Next $5,000,000 of assets
Over $10,000,000 of assets
ANNUAL RATE
1.00%
0.85%
0.75%
0.50%
For account relationships of less than $1 million, the following fixed rate fee schedule applies:
$0 - $250,000
$250,001- $1,000,000
1.50%
1.25%
Although the Management Fee listed above is a standard fee, such fee in some circumstances is negotiable
according to a variety of factors; including but not limited to the size and type of account, complexity,
relationship with the Company (including with respect to services provided to client by the Company or its
affiliates), its owners and/or employees.
Clients grant the Company written authority to receive quarterly payments directly from the client's account
held by the respective custodian. The Company will send to the client an informational invoice, showing the
amount of the fee to be charged to the account, the value of the client's assets on which the fee is based, and the
specific manner in which the fee is calculated. Fees for each quarter are noted on the monthly statement each
client receives from the custodian one month after quarter-end. Clients may elect to be billed for fees rather
than having them deducted from their accounts.
In addition to the above Management Fee and the BAA service fee, Investment Advisory Accounts are assessed
brokerage and transaction charges with respect to trades placed for the account. These charges are paid to the
account custodian for effecting transactions and may be higher or lower than transaction charges or
commissions the client may pay at other broker-dealers. Please refer to the section below (Item 12) entitled,
6
“Brokerage Practices” for additional information. Clients do not pay a separate custodial fee.
Inherent Conflict of Interest:
Because we charge an ongoing asset-based fee, The Company is incentivized to
increase the managed assets in a client account, thereby increasing the fees paid by its clients.
TERMINATION
An Advisory Agreement may be terminated at any time for any reason by either party upon thirty days (30)
days’ written notice to the other. The Company will reject any termination instructions, including account
liquidation instructions, unless Client provides those instructions in writing. The client will be entitled to a
pro-rata refund of any prepaid quarterly account fee based upon the number of days remaining in the quarter
after the termination date.
COMPENSATION FOR THE SALE OF SECURITIES OR OTHER INVESTMENT PRODUCTS
Typically, the Company recommends no-load and load-waived mutual funds to its clients. Clients benefit from
not paying a sales commission to purchase a mutual fund but may pay a nominal transaction fee to the account
custodian.
Additionally, it is possible for a client to also incur certain charges imposed by third parties other than the
Company in connection with investments made through the account. These charges may include, but are
not limited to, mutual fund 12b-1 distribution fees and/or service fees (paid to the custodian), or certain
deferred sales charges on previously purchased mutual funds purchased while the account assets were
custodied at a prior custodian. These fees are disclosed in the fund's prospectus provided to the client by
outside third parties.
Buy All Accounts (BAA) Service
Clients may choose to participate in the BAA service in one of two ways. First, clients may choose to
participate in the BAA service in which the Company can trade in subaccounts of clients’ variable
annuities.
Second, clients may choose clients may choose to participate in the BAA service where the Company does
not trade nor manage the client’s account. Such participation enables the Company to consider
information about the client’s investments held with other custodians when rendering advice with
respect to the Investment Advisory Account, as well as to provide non-discretionary advice to such client
as to the investments in the accounts reported through BAA. Such clients are under no obligation to act
on or consider any advice that may be rendered by the Company with respect to such accounts, and
clients may direct the investments in such accounts in any manner they desire with respect to any
accounts reported through BAA that are not included in the Investment Advisory relationship. The
Company has no responsibility to direct investments in, and/or place trades for such accounts.
In both scenarios clients are charged the annual fee payable quarterly in advance. The value of such
accounts is included in the overall value of the Investment Advisory Account for purposes of calculating
the Company’s Management Fee.
Financial Planning Services
For select clients the Company will prepare a financial plan or module, the Company charges either a fixed fee that ranges
between $1,000 and $25,000 for financial planning and/or estate planning services. When the scope of the services has been
agreed upon, a determination will be made as to the applicable fee. The final fee, subject to negotiation, is directly dependent
upon the client’s financial situation, the complexity of the requested service, and the time involved in providing the client
with the requested service. Generally, if the client chooses to proceed, 100% of the estimated fee is due and payable upon
completion of the contracted services. However, the Company may, in its discretion, request that the client pay an initial
retainer in advance of any services rendered and progress payments as services are performed with the balance due and
payable upon completion of the contracted services. Under no circumstances will the Company require prepayment of a fee
more than six months in advance and in excess of $1,200.
7
Additionally, the Company may provide its financial planning services for an Annual/Ongoing Planning
Maintenance fee. The fee is dependent upon the engagement scope and is billed in 4 equal installments by the
Company (in advance) at the start of each subsequent calendar quarter.
Retirement Plan Consulting Fee
The charge for consulting may be based on a percentage of assets held in the plan or flat-rate basis as
negotiated between the plan and the Company. Fees are typically billed quarterly in advance and deducted out
of plan assets. However, fees can also be billed arrears, and/or be invoiced on a quarterly basis as well. Fees
are detailed in the respective retirement plan consulting agreement.
The Company charges $2,500 to set up a new retirement plan.
In connection with its services to 401(k) plans, the Company is acting as a fiduciary to its’ clients plans under the Employee
Retirement Income Security Act (“ERISA”). For purposes of providing investment advice, the Company may provide advice
according to one of the following roles:
Non-discretionary investment advice about asset classes and investment alternatives available for the clients’ plans in
accordance with the Plan’s investment policies and objectives; or Discretionary investment manager as defined in Section
3(38) of ERISA that is ongoing and continuous discretionary investment management with respect to the asset classes and
investment alternatives available under the Plan in accordance with the Plan’s Investment Policy Statement. Under this
authority, Adviser may remove or replace the investment alternatives available under the Plan at its discretion.
The Company charges an advisory fee according to the following fixed rate fee schedules:
PORTFOLIO VALUE
$0 - $1,999,999.99 of assets
$2,000,000 - $3,999,999 of assets
$4,000,000 - $5,999,999 of assets
$6,000,000 - $7,999,999 of assets
$8,000,000 - $9,999,999 of assets
10,000,000 – 14,999,999 of assets
$15,000,001 - Over
ANNUAL RATE
0.75%
0.70%
0.65%
0.60%
0.55%
0.50%
0.45%
The company charges $1,000 to set up new SIMPLE Plans.
For SIMPLE Plans, the Company charges an advisory fee according to the following fixed rate fee schedules:
PORTFOLIO VALUE
$0 - $999,999.99 of assets
$1,000,000 - $1,999,999 of assets
$2,000,000 - $3,999,999 of assets
$4,000,000 - $5,999,999 of assets
$6,000,000 - $7,999,999 of assets
$8,000,000 - $9,999,999 of assets
10,000,000 – 14,999,999 of assets
$15,000,001 - Over
ANNUAL RATE
0.95%
0.75%
0.70%
0.65%
0.60%
0.55%
0.50%
0.45%
For SIMPLE Plans, the company deducts the fees in arrears
Although the Management Fee listed above is a standard fee, such fee in some circumstances is negotiable
according to a variety of factors; including but not limited to the size and type of account, complexity,
relationship with the Company (including with respect to services provided to client by the Company or
its affiliates), its owners, and/or employees.
For plans with more than 100 participants, additional fees may apply and are dependent upon the level of
8
services required by the plan.
For plans with multiple office locations, additional service fees may apply.
These fees may be negotiable in the Company’s sole discretion, based on certain factors including, but not
limited to plan size, the number of plan participants, and the plan’s relationship with the Company.
The fee is based upon a percentage of the value of the portfolio, as it may increase or decrease during the
engagement, and generally is billed quarterly in advance, but may for some plans be billed in arrears. The
amount is calculated using the value of the portfolio based on the prior quarter’s ending market value.
Only if other payment/reimbursement provisions are agreed to, The Company’s fees are billed directly to and
paid from the plan's participant accounts by the plan custodian. However, if the annual advisory fee is less than
$2,500 (based on the above fee schedule), then the plan sponsor is responsible for paying the difference
between the amounts paid by the plan's participant accounts and $2,500. Any fees that are the plan sponsor’s
responsibility are billed directly to the plan sponsor. Any fees paid by the participant accounts will be fully
disclosed on the participants' quarterly statement (unless reimbursed by the plan sponsor). Any participant-
level reporting is the responsibility of the plan’s record keeper, and not the Company.
Retirement Plan Termination
An Advisory Agreement may be terminated at any time for any reason by either party upon ten days (60)
days’ written notice to the other. The Company will reject any termination instructions, including account
liquidation instructions, unless Client provides those instructions in writing. The client will be entitled to a
pro-rata refund of any prepaid quarterly account fee based upon the number of days remaining in the quarter
after the termination date.
Administrative Services
ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Fees for administrative services are negotiated based upon the scope and complexity of the services being
provided.
This Item is not applicable to the Company.
ITEM 7. TYPES OF CLIENTS
The Company generally provides investment advice to individuals; 401(k), defined contribution, and defined
benefit pension plans; trusts; estates; and charitable organizations.
With respect to Client Advisory Accounts, the Company generally does not manage accounts with initial deposits less
than $100,000. Accounts below this minimum may be negotiable and accepted on an individual basis at the Company’s
discretion or enrolled in our automated investment program.
With respect to 401(k) plan clients, when the Company’s advisory fee amounts to less than$2,500 per year,
then the plan sponsor is responsible for paying the difference between the amount paid from plan assets and
$2,500.
ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
Methods of Analysis
. The Company's investment process is designed to allocate client assets using a global
asset class diversification strategy to manage portfolio risk (using mutual funds, individual bonds, and
alternative fixed income investments to include but not limited to public non-traded REITS and Interval funds).
The Company identifies permissible investments for client portfolios after examining historical returns as
benchmarked to peer performance and asset class indices, risk and valuation measurements, internal costs,
sales loads, and manager tenure. The Company selects, monitors and assesses performance of mutual fund
advisors on an ongoing basis.
The Company also provides advice as to the following types of securities: exchange-traded funds (“ETFs”);
9
corporate debt securities (other than commercial paper); certificates of deposit; municipal securities; U.S.
Government and agency obligations; and FDIC-insured equity-linked certificates of deposit.
Investment Strategies and Related Risks.
Investment strategies used by the Company in managing
clients’ assets include long-term securities purchases (i.e., securities held at least one year) and short-term
securities purchases (i.e., securities sold within one year of purchase).
A mutual fund pools money together from many small investors and the fund’s manager may purchase stocks,
bonds or other securities within the fund. Investors that contribute money to a mutual fund get a stake in all its
investments. The price for a share of a mutual fund is determined by the fund’s net asset value (“NAV”), which
is the total value of the securities the fund owns divided by the number of shares outstanding. A mutual fund's
NAV changes every day, depending on the price fluctuations of the fund's holdings. Typically, the Company
recommends no-load and load-waived mutual funds to its clients. Clients benefit from not paying a sales
commission to purchase a mutual fund but may pay a nominal transaction fee to the account custodian. A
sales commission may be imposed on client portfolios purchasing mutual funds through certain custodians.
Mutual funds face risks based on the investments they hold. Depending upon the types of mutual funds
selected fora client’s account (which is dependent upon such client’s investment profile), one or more of the
Call Risk.
following risks, as well as certain additional risks, should be considered:
The possibility that falling interest rates will cause a bond issuer to redeem or call its bond before
Country Risk.
the bond's maturity date.
The possibility that a bond issuer will fail to repay interest and principal in a timely manner. Also
The possibility that political events (a war, national elections), financial problems (rising
inflation, government default), or natural disasters (an earthquake, a poor harvest) will weaken a country's
Credit Risk.
economy and cause investments in that country to decline.
Currency Risk.
called default risk.
The possibility that a group of stocks in a single industry will decline in price due to
The possibility that increases in the cost of living will reduce or eliminate a fund's real inflation-
The possibility that a bond fund will decline in value because of an increase in interest
The possibility that returns could be reduced for Americans investing in foreign securities
because of a rise in the value of the U.S. dollar against foreign currencies. Also called exchange-rate risk.
Income Risk. The possibility that a fixed-income fund's dividends will decline as a result of falling overall
Industry Risk.
interest rates.
Inflation Risk.
developments in that industry.
Interest Rate Risk.
adjusted returns.
Manager Risk.
rates.
The possibility that an actively managed mutual fund's investment adviser will fail to execute
Market Risk.
the fund's investment strategy effectively resulting in the failure of stated objectives.
The possibility that fund prices (e.g., stock, bond, alternative investments) overall will decline
over short or even extended periods. These markets tend to move in cycles, with periods of rising or falling
Principal Risk.
prices.
The possibility that an investment will decline in value, or "lose money," from the original or
invested amount.
With respect to alternative investments selected or recommended for a client’s account, the following risks
Diversification Risk.
should be considered:
Fixed income alternative investments are typically "non-diversified" and changes in the
market value of a single holding may cause greater fluctuation in the alternative investment’s net asset value
than in a "diversified" fund. Additionally, closed-end non-traded REITS are “best efforts” offerings. If they raise
substantially less than the maximum offering, they may not be able to invest in a diverse portfolio of real estate
and real estate-related investments, and the value of your investment may fluctuate more widely with the
Economic Risk.
performance of specific investments.
Economic factors may adversely affect all markets; therefore, even if the alternative
investments are seemingly in a different industry, the investment may be affected. For example, a Non-Traded
REIT is subject to the economic risks of its underlying tenants, in addition to the economic risks in the real
10
Leverage Risk.
estate industry.
Many alternative investments invest in a variety of derivatives, which may involve potentially
greater risks than investing directly in securities and more traditional asset classes. Furthermore, an
alternative investment which is an “emerging growth company” can have very stringent credit and loan
covenants with the offering’s financiers. This may limit its ability to borrow money for growth or ongoing
Liquidity Risk.
operations.
Alternative investments invest in illiquid or restricted securities, which may limit your ability
to sell your position or limit your ability to withdraw funds when needed. Additionally, alternative
investments differ in their liquidity and no public market exists to buy or sell these securities. Furthermore,
in their prospectuses, the fund can reserve the right for when they will provide liquidity or distribute
dividends, if they believe doing so would harm investors in the fund. Generally, alternative investments
provide for quarterly redemptions up to 5% of the funds value, while other offerings can provide for daily
liquidity. Therefore, these offerings are suitable only for eligible, long-term investors who are willing to forgo
liquidity, or put capital at risk for an indefinite period of time, and for those investors who are not dependent
Tax Risk.
on the advertised dividends for their personal daily needs.
An alternative investment, in paying distributions may consist solely of a return of capital (i.e.
from my original investment) and not a return of net profit. Sources of distributions to shareholders for tax
reporting purposes will depend upon the Fund’s investment experience during the remainder of its fiscal
year and may be subject to changes based on tax regulations
With respect to individual securities selected or recommended for a client’s account, the following risks should
Equity securities.
be considered:
Prices of equity securities change in response to many factors including the historical and
prospective earnings of the issuer, the value of its assets, general economic conditions, interest rates, investor
Corporate debt securities,
perceptions and market liquidity.
municipal securities and U.S. Government securities face risks related to
interest rates, credit risk and income. For instance, bond values are inversely related to changes in interest
rates. In most instances, if interest rates rise, bond values will decline and vice versa.
Certificates of deposit (“CDs”), although commonly considered to be safe investments, nonetheless carry
certain risks, including those relating to lower yields, and interest rate fluctuation. Because of the relative
safety and short- term nature of CDs, yields on CDs tend to be lower than other higher risk investments. In
addition, like all fixed income securities, CD prices are susceptible to fluctuations of interest rates. If interest
rates rise, the market price of outstanding CDs will generally decline.
FDIC-insured equity-linked CDs may tie the rate of return to the performance of a stock index (for example,
the S&P 500 Composite Stock Price Index). Generally, the FDIC insurance covers the principal and any
insured returns within the limits of the equity-linked CDs. The terms of these CDs vary; typically, the term is
three to eight years. Therefore, there is no guarantee that any payment in excess of the principal amount will
be paid. Such CDs face additional risks, primarily liquidity risk, because you will have limited opportunities,
if any to redeem an equity-linked CDs before maturity. Additionally, if it is sold before maturity, it may be
worth less than its purchase amount or face value. Principal value is guaranteed if held to maturity, subject to
FDIC limits. Investors may incur substantial loss if the security is sold before maturity.
The foregoing is a brief discussion of some of the different types of risk investors typically encounter. For a
comprehensive discussion of a specific investment’s material risks, an investor should review the entire
prospectus.
ITEM 9. DISCIPLINARY INFORMATION
This Item is not applicable to the Company.
ITEM10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Neither the principals of the Company, nor any related persons, are registered, or have an application
pending to register, as a futures commission merchant, commodity pool operator, a commodity trading
11
advisor, or an associated person of the foregoing entities.
ITEM 11. CODE OF ETHICS
The Company has established a subadvisor relationship with Brown Advisory LLC, to manage municipal fixed
income portfolios on behalf of its eligible clients. Brown Advisory charges a separate management fee to the
client account. The Company does not receive any fees or services from Brown Advisory for the clients
referred to Brown.
The Company has adopted a Code of Ethics, predicated on the principle that the Company owes a fiduciary
duty to its clients. The Code of Ethics establishes certain policies and procedures for the Company’s
employees; the Code sets forth a policy with respect to the following: receipt of gifts; personal securities
trading; and outside business activities. The Code also includes a prohibition on insider trading. The Code is
administered by the Company’s Chief Compliance Officer, and each employee must review the Code and
acknowledge their receipt and compliance with the Code at least annually.
Supervised and Access persons of the Company may own, purchase, or sell securities which are also
recommended for purchase or sale to clients. Such personal securities trading poses the potential for conflicts
between the interests of the Company’s related persons and the interests of clients, including conflicts in
connection with the following: pricing of securities; commission rates received; timing of transactions; and
limited availability of securities. In addition, related persons of the Company may at times buy or sell
securities for a client’s account at or about the same time that such related person trades in the same
securities for his or her own account.
To address these potential conflicts, the Company has determined that orders for clients shall always take
priority over orders for the related persons of the Company. Clients will always be accorded the best price
and execution in those transactions involving the same security. In addition, when trades for clients and
Company employees are placed on an aggregated basis, such trades must be made in compliance with the
Company’s Trade Aggregation Policy. This Policy requires that all accounts participating in an aggregated
trade order shall receive the average price and pay a pro-rata portion of commissions. Such purchases or
sales by Company employees must also be made in compliance with the Code of Ethics, which prohibits
certain acts to avoid potential conflicts of interest. In particular, the Code provides that no employee may
engage in personal securities transactions with respect to limited offerings or an initial public offering
(“IPO”) or any new issue of equity securities without obtaining advance preclearance of such transactions. In
addition, the Code prohibits employees from “front running” client accounts, which is a practice generally
understood to be employees personally trading ahead of client accounts.
Supervised and Access persons of the Company, are eligible for incentive compensation for increasing the
Company’s business. Therefore, employees of the firm have an inherent conflict of interest in recommending
potential clients to “rollover” their qualified retirement assets from any vehicle (401(k) plans, IRA’s, Roth
IRA’s etc.), in addition to this disclosure the Company has implemented account opening due diligence
procedures which aim to educate the client as to their choices, and to insure that such actions are in the
clients’ best interest.
Current or prospective clients may obtain a copy of the Company’s Code of Ethics upon request.
ITEM 12. BROKERAGE PRACTICES
The Company does not maintain custody of your assets that we manage, although we may be deemed to
have custody of your assets if you give us authority to withdraw assets from your account (see Item 15-
Custody below). Your assets must be maintained in an account at a "qualified custodian,” generally a
12
broker- dealer or bank. Therefore, the Company requires that clients establish brokerage accounts with
Schwab Institutional (“Schwab”), a division of Charles Schwab & Co., Inc.; and Fidelity Registered
Investment Advisor Group (“Fidelity”), a division of Fidelity Investments to maintain custody of clients'
assets and to effect trades for their accounts.
We are independently owned and operated and are not affiliated with Schwab, or Fidelity. Schwab, or
Fidelity, will hold your assets in a brokerage account and buy and sell securities when we instruct them to.
We require that you use one of these custodians by entering into an account agreement directly with them.
We do not open the account for you, although we will assist you in doing so. Not all advisors require their
clients to use a particular broker-dealer or other custodian selected/recommended by the advisor. Even
though your account is maintained at Schwab, or Fidelity, we can work with other brokers to execute
trades for your account as described below.
We seek to select a custodian/broker that will hold your assets and execute transactions on terms that
overall are most advantageous when compared with other available providers and their services. We
consider a wide range of factors, including:
1)
2)
3)
4)
5)
6)
7)
8)
9)
10)
11)
Combination of transaction execution services and asset custody services (generally without a
separate fee for custody)
Capability to execute, clear, and settle trades (buy and sell securities for your account)
Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests,
bill payment, etc.)
Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
[ETFs], etc.)
Access to mutual funds and other investments that are otherwise generally available only to
institutional investors or would require a significantly higher minimum initial investment.
Availability of investment research and tools that assist us in making investment decisions
Quality of services
Competitiveness of the price of those services (commission rates, margin interest rates, other fees,
etc.) and willingness to negotiate the prices
Reputation, financial strength, security and stability
Prior service to us and our clients
Availability of other products and services that benefit us, as discussed below
The custodians do not charge separately for custody but are compensated by account holders through
earned interest on un-invested cash, money market management fees, commissions or other transaction-
related fees for securities trades that are executed through the custodian or that settle into the custodian’s
accounts. Not all advisers require their clients to use the services of particular custodians. These
custodians are registered broker- dealers and are not affiliated with The Company.
In addition to commissions and fees, Schwab, and Fidelity, charge you a flat dollar amount as a "prime
broker" or "trade away" fee for each trade that we execute through a different broker-dealer. These fees are
in addition to the commissions or other compensation you pay the executing broker-dealer. Therefore, to
minimize your trading costs, we have Schwab, and Fidelity, execute most trades for your account. We have
determined that having Schwab and, Fidelity, execute most trades is consistent with our duty to seek "best
execution" of your trades. Best execution means the most favorable terms for a transaction based on all
relevant factors, including those listed above.
The Company has established its brokerage and custody relationships with Schwab and, Fidelity, based upon
the Company’s assessment of the standard of service needed to properly manage an investment advisory
practice. The Company from time to time, reviews its criteria and assesses the commitment of these
broker/custodians to maintaining or surpassing industry standards in technology, service innovation, and
adviser support. The decision to use these custodians recognizes that price is not the only factor involved
when executing client trades, but rather the value maximized in the client portfolio given each of the stated
investment objectives and constraints. Though the Company believes these companies provide the best
13
overall value for client custody and brokerage activity, the client can likely find less costly alternatives to
facilitate the execution of equity or fixed income trading. In other words, clients may on occasion pay
commissions higher than those charged by other broker-dealers because of the Company’s routine
recommendation that clients use these specific custodians.
i.e
Clients may direct the Company in writing to engage in directed brokerage transactions (
., using a broker
other than Schwab, or Fidelity,) Should the client choose to do so, the Company’s ability to obtain the best
price and execution with respect to such client’s account may be hindered, and the decision by a client to
direct brokerage to a particular broker-dealer may cost the client more money. Specifically, a client may
pay brokerage commissions that exceed the commissions charged by other broker-dealers, including
Schwab, and Fidelity, In addition, a client who designates the use of a particular broker/dealer should
understand that it will lose possible advantages that other clients derive from the aggregation of orders for
several clients as a single transaction for the purchase or sale of a particular security. The ability of the
Company to effectively negotiate commission rates could also be affected by a client designating the use of a
specific broker/dealer, and as a result, the Company may not obtain best execution on behalf of the client,
who may pay materially disparate commissions, greater spreads or transaction costs, or receive less
favorable net prices on transactions for the account than would otherwise be the case.
When placing trades in Variable annuity subaccounts, client recognizes the limited options and underlying
costs and inability to find a less expensive share class.
Orders for the same security entered on behalf of more than one client may be aggregated (bunched) when
the Company believes doing so to be in the best interests of all participating clients. Subsequent orders for
the same security entered during the same trading day may be aggregated with any previously unfilled
orders; filled orders shall be allocated separately from subsequent orders. All clients participating in each
aggregated order shall receive the average price and if applicable, pay a pro-rata portion of commissions.
Instances in which client orders will not be aggregated include, but are not limited to, the following:
1)
2)
Clients directing the Company to use certain broker/dealers, in which case such orders shall be
separately affected.
Traders and/or portfolio managers determine that aggregation is not appropriate because of
market conditions; and Portfolio managers must affect the transactions at different prices, making
aggregation unfeasible.
The custodians provide us and our clients with access to their institutional brokerage services (trading,
custody, reporting, research and related services), many of which are not typically available to retail
customers. The custodians also make available to the Company various products and support services. Some
of these services help us manage or administer our clients' accounts, while others help us manage and grow
our business. Support services are generally available on an unsolicited basis (we don't have to request them)
and at no charge to us. Such products and services benefit the Company because the Company does not have to
produce the research or pay for such research, products or services.
SERVICES THAT BENEFIT YOU.
The Custodians institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through the custodians include some to which we might not otherwise have access or that would require a
significantly higher minimum initial investment by our clients. The Custodians services described in this
paragraph generally benefit you and your account.
SERVICES THAT MAY NOT DIRECTLY BENEFIT YOU.
The Custodians also make available to the Company other products and services that benefit us but may not
directly benefit you or your account. These products and services assist us in managing and administering
our clients' accounts. They include investment research, both Schwab's, and Fidelity’s, own and that of third
parties. We may use this research to service all or a substantial number of our clients' accounts, including
14
accounts not maintained specifically at Schwab, or Fidelity, in addition to investment research, the
custodians also make available software and other technology that:
1)
2)
3)
4)
5)
Provide access to client account data (such as duplicate trade confirmations and account statements),
Facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts),
Provide research, pricing information and other market data,
Facilitate payment of the Company's fees from its clients' accounts, and
Assist with back-office support, recordkeeping and client reporting.
The custodians discount or waive fees it would otherwise charge for some of these services to the Company.
This creates an incentive for the Company to select the custodians for its clients’ accounts. While as a
fiduciary, the Company endeavors to act in its clients' best interests, the Company’s requirement that clients
maintain their assets with one of these custodians is based in part on the benefit to the Company of the
availability of some of the foregoing products and services and not solely on the nature, cost or quality of
custody and brokerage services provided by the custodian, which creates a conflict of interest. In other
words, it is possible for clients on occasion to pay commissions higher than those charged by other broker-
dealers, due to these soft dollar benefits the Company receives from the respective custodians. The Company
believes that such conflicts and discussion of its relationship interests with the custodians, is addressed and
mitigated by making this disclosure to its clients.
Many of these services generally are used to service all or a substantial number of the Company's accounts,
even though the accounts may not be clients with that particular custodian. The custodians also provide the
Company with other services intended to help the Company manage and further develop its business
enterprise.
These services include consulting, publications and presentations on practice management, information
technology, and business succession, access to employee benefits providers, human capital consultants,
insurance providers, regulatory compliance, marketing, and general business needs. The custodians may
provide some of these services. Other times, they will arrange for third-party vendors to provide the services
to us. The custodians may also discount or waive its fees for some of these services or pay all ora part of a third
party's fees. The custodians may also provide us with other benefits, such as occasional business
entertainment of our personnel.
Within the last fiscal year, brokers with which the Company does business made available to the Company and
its related persons access to the following:
1)
Software and other technology that(i) provides access to client account data,(ii) facilitates trade execution,
(iii) provides research and pricing information, (iv) facilitates fee payment, and (v) assists with back-
2)
office support; and
Publications and presentations on (i) practice management, (ii) information technology, (iii)
business succession, (iv) regulatory compliance, and (v) marketing.
With respect to financial planning clients, the Company lacks discretionary authority to determine
securities to be bought or sold for the client, the amount of securities to be bought or sold, the broker or
dealer to be used, or the commission rate paid. The client is free to choose the sources through which
investment advisory recommendations to be implemented.
With respect to financial planning clients, the Company has no preference where client’s custody assets or
the brokers that are selected for trading. However, when the client desires to create a portfolio of mutual
funds and/or specific securities, the Company will provide the client with the names of brokers from which
the client may choose if asked. The investment adviser representative working with the client will make
recommendations to the client as to which broker, he/she wishes to deal with. The investment advisor
15
representative will base this recommendation on his/her professional experience in working with a
particular broker/custodian, the needs of the client and the services provided by the broker/custodian,
such as: ability to execute trades, margin rates, on-line access to accounts, transaction charges, duplicate
monthly statements, access to mutual funds, including lower sales charges than for direct purchases, and
lower minimum purchase amounts. The Company does not expect that clients will pay commissions to
brokers the investment adviser representative recommends that are higher than those obtainable from
other brokers for comparable client services. However, there can be no assurance that clients will pay the
lowest commissions available.
The Company reviews approved mutual fund share classes as part of its investment committee deliberations,
on an as needed basis (e.g. reviewing new funds). The Company does not believe that there is a “one size fits
all” solution as to which share class should be used for any specific client or set of circumstances. At all times
The Company’s philosophy is to do what is in the “Best Interests” of the client. Sometimes this is the
exercise of professional judgement and consideration of various factors, such as investment size, time
horizon to be held, transaction fee, etc. As with all investment expenses, such charges reduce investment
performance, and a cost benefit assessment is made by The Company when recommending a specific share
class when more than one is available. Additionally, with ETFs trading for free at Schwab, and Fidelity the
Company does not believe that this change categorically requires that it abandon mutual funds and instead use
ETFs.
ITEM 13. REVIEW OF ACCOUNTS
For Client Advisory Accounts, each client account is reviewed at least annually by the account’s Investment
Adviser Representative (“IAR”), who may be part of a team responsible for managing the account. In
connection with such review, the client’s portfolio allocation is compared to the account’s investment
policy and a determination is made by the IAR as to whether a recommendation should be made to the client
regarding portfolio re-balancing. Additionally, the client and the IAR assigned to the account will meet on
an “as needed” basis for a more comprehensive review of the portfolio's performance and to discuss changes
in investment objective, portfolio re-balancing, investment restrictions or other matters as required by the
client.
In general, the Company’s’ IARs are responsible for reviewing accounts, whether individually or as part of a
team. Depending on a variety of factors (including the number of new accounts established during the year;
whether the IAR operates individually or as part of a team with respect to certain accounts; the number of
additional IARs hired by the Company during the year; etc.) each reviewer could have responsibility for a
small handful of accounts (e.g., fifteen) to a large number of accounts (e.g., over 100). Given the factors
determining the number of accounts reviewed by each IAR, these numbers could fluctuate throughout the
year.
The Company furnishes written performance reports to its Client Advisory Accounts on a quarterly basis. The
reports are intended to inform clients as to how their investments have performed during the selected
period. In addition, the client receives a monthly account statement from the custodian showing account
activity, as well as positions held in the account at month end. Clients also receive a confirmation of each
transaction that occurs within his or her account.
For financial planning accounts, the Company encourages an annual review. In most cases, a review of a client’s
financial plan would require a new engagement between the client and the Company.
401(k) Retirement Plan Fiduciaries are provided annual written reports assessing the overall investment
process of the plan’s operation. The report assesses investment cost, and investment screening,
monitoring and supervision processes. Investment performance is benchmarked to peer group averages and
market indices. Likewise, such factors as risk, style consistency, suitability, and manager tenure are
reviewed for each individual mutual fund offered on its platform.
16
ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION
The Company has no new and ongoing Promoter relationships. This excludes relationships for which the
company still pays individuals for their past Promoter work.
OTHER ECONOMIC BENEFIT
We receive an economic benefit from the custodians of our client accounts as support for products and
services the custodians make available to us and other independent investment advisors whose clients
maintain their accounts at Schwab, or Fidelity, In addition, these custodians have agreed to pay for certain
products and services for which we would otherwise have to pay. These products and services, how they
benefit us, and the related conflicts of interest are described above (see Item 12-BrokeragePractices).
On occasion, a client may need services provided by a third-party qualified plan administrator. If requested,
the Company may refer the client to American Retirement Plan Services ("ARPS"), who serves as plan
administrator for the Company’s qualified plan. Although there is no referral arrangement between ARPS and
the Company, as a result of referrals made by the Company in the past, ARPS charges a reduced fee for the
ongoing administration services it provides with respect to the Company’s qualified plan. Consequently, a
conflict between the interest of the Company and those of its clients exists, and to mitigate this conflict of
interest, the Company is making this disclosure. The client is under no obligation, contractual or otherwise, to
retain the services of ARPS.
CF Cash Program
The Company informs its clients and prospective clients of the Cantor Fitzgerald Insured Cash Program℠
otherwise known as “CF Cash Program.” The CF Cash Program is a deposit bank account program established
and administered by StoneCastle Cash Management, LLC (“StoneCastle”) to benefit individual investors by
offering a cash management solution designed to enhance returns on cash savings while providing 100% FDIC
insurance protection. The Company receives an administrative fee from StoneCastle based on the average
daily balance of each individual account referred by the Company who participates in the CF Cash Program.
ITEM 15. CUSTODY
The Company is deemed to have “custody” over certain of its Client Advisory Accounts, based on certain
factors which necessitate compliance with other aspects of the SEC’s Custody Rule 206 (4)-2. Therefore, to
comply with the SEC’s “Custody Rule,” the Company has taken steps to ensure that the qualified custodian
maintaining such accounts sends to clients quarterly account statements: (i) identifying the amount of funds
and of each security in the account at the end of the quarter; and (ii) setting forth all transactions in the
account during the quarter. Thus, clients should expect to receive from their account custodians such
statements on a quarterly basis and are encouraged to review such statements carefully. In addition, the
Company sends each of its clients a quarterly performance report and urges its clients to compare these reports
with those received from the account custodian.
rd.
The Company is deemed to have “custody” of its clients’ funds by accommodating its clients with “Standing
party. The Company relies on the
Letters of Authorization” to facilitate the periodic transfer of funds to a 3
recordkeeping regulatory exception provided by the SEC to exclude these accounts from its annual surprise
audit conducted by an independent CPA firm.
Additionally, The Company is deemed to have “custody” of some of its clients’ funds and is required to undergo
an annual surprise audit from an independent CPA firm.
ITEM 16. INVESTMENT DISCRETION
The Company typically requires discretionary authority to manage securities accounts on behalf of certain
clients. Such clients are required to execute a limited power of attorney, as part of the Company’s standard
engagement with such clients, in order that the Company may carry out this authority. Notwithstanding this
discretionary authority, the Company manages the accounts only in accordance with the investment mandates,
guidelines, and/or restrictions (if any) that have been provided by clients. For instance, client-imposed
restrictions can include restrictions on specific securities or restrictions on categories of securities, such as by
17
industry or based on social criteria (see Item 4-AdvisoryBusiness).
In accordance with its diminished capacity policy, the Company reserves the right to withhold asset
disbursements, in accordance with state law, if the Company has reason to believe that the disbursement
request is an attempted abuse of a client due to the client’s diminished capacity.
ITEM 17. VOTING CLIENT SECURITIES
Generally, the Company does not assume responsibility to vote proxies on behalf of its clients. Proxy voting is a
client responsibility, and as a result, the Company will not take any action involving legal matters, including
securities class actions on behalf of its clients with respect to securities or other investments held in the client’s
account. The company advises its clients as to proxies that arise.
The custodian maintaining the client’s account will send proxy and class action information directly to such
client. If the Company receives any such material on behalf of a client, it will promptly forward that material to
the client. However, upon a client’s request, the Company may assist clients in the collection of data for the
purpose of filing a claim should they relate to investments purchased on such client’s behalf while a client of the
Company.
Rarely, the Company assumes responsibility to vote proxies on behalf of clients. This usually stems from a
corporate trustee relationship where the company is an investment advisor of a “covered trust”. A separate
agreement must be executed between the Company and the client for the Company to assume responsibility to
vote proxies on a client’s behalf.
As discussed above (Item 4- Advisory Business and in Item 8-Methods of Analysis, Investment Strategies and
Risk of Loss) the Company primarily recommends that its clients invest in mutual funds; therefore, most
proxies are voted by the investment advisor of the respective fund companies.
Current or prospective clients may obtain a copy of the Company’s Proxy Voting policy and procedure upon
request.
ITEM 18. FINANCIAL INFORMATION
This Item is not applicable to the Company
ITEM 19. REQUIREMENTS FOR STATE-REGISTERED ADVISERS
This Item is not applicable to the Company
18
Glass Jacobson Investment Advisors, LLC
10055 Red Run Blvd. Suite 160
Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
Part 2B of Form ADV: Brochure Supplement
1
Mercer Global Advisors Inc. has entered into an agreement to acquire Glass Jacobson Investment
Advisors, LLC. The transaction closed on November 30, 2025, and resulted in a change of ownership.
Mercer Global Advisors Inc. owns one hundred (100%) percent of the operating assets of Glass
Jacobson Investment Advisors, LLC. Due to the acquisition of Glass Jacobson Investment Advisors, LLC,
the firm has provided notice to affected clients of the assignment to Mercer Global Advisors Inc. (a SEC-
registered investment advisor) of such clients’ advisory arrangements with Glass Jacobson Investment
Advisors, LLC to the extent required under applicable law. Once the account transfer process is
complete at the custodial level, Glass Jacobson Investment Advisors, LLC will file a Form ADV-W to
wind down the advisory business.
Although these Registered Investment Advisors are being portrayed as advisors of Glass Jacobson,
please be advised that Glass Jacobson is in a transition period to merge its firm into Mercer Global
Advisors.
Copies of Mercer Global Advisors’ ADV Part 2A, Form CRS and Privacy Notice are available upon
request by calling 888.885.8101 or at www.merceradvisors.com.
2
Michael K. Creamer
Glass Jacobson Investment Advisors, LLC 10055 Red Run Boulevard, Suite 160 Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
�
This brochure supplement provides information about Michael K. Creamer, and supplements the information
contained in the brochure of Glass Jacobson Investment Advisors, LLC (“Glass Jacobson” or the “Company”). You
should have received a copy of that brochure. Please contact Jonathan Dinkins, Chief Compliance Of
icer of Glass
www.adviserinfo.sec.gov
Jacobson, if you did not receive Glass Jacobson’s brochure or if you have any questions about the contents of this
.
supplement. Additional information about Mr. Creamer is available on the SEC’s website at
ITEM 2. EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
He received a B.S. in Accounting from St. Joseph’s University in 1990. Mr. Creamer holds the following professional
designations: CPA, CFP®, CDFA™, AIF® and ADPA®.
Mr. Creamer was born in 1968 and joined Glass Jacobson in 2011 as an investment advisor representative. He
holds a dual registration with Mercer Global Advisors, Inc., as a Sr. Wealth Advisor, joining Mercer in December
2025. In January 2026, Mr. Creamer was named as Director, Tax Services for Mercer Advisors Tax Services, LLC.
Certi�ied Public Accountant (CPA).
�
�
Code of Professional Conduct
�
�
�
licts of interest (and obtain client consent if a con
identiality, disclose to the client any commission or referral fees, and serve the public interest when providing
CPAs are licensed and regulated by their state boards of accountancy. While
state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally
include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a
concentration in accounting), minimum experience levels (most states require at least one year of experience
providing services that involve the use of accounting, attest, compilation, management advisory,
inancial advisory,
tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful
passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion
of 40 hours of continuing professional education (CPE) each year (or 80 hours over a two year period or 120 hours
over a three year period). Additionally, all American Institute of Certi
ied Public Accountants (AICPA) members are
which requires that they act with integrity, objectivity, due
required to follow a rigorous
lict exists), maintain client
care, competence, fully disclose any con
�
Code of Professional
con
Conduct
inancial services. The vast majority of state boards of accountancy have adopted the AICPA’s
within their state accountancy laws or have created their own.
TM
CERTIFIED FINANCIAL PLANNERTM (CFP®).
�
The CERTIFIED FINANCIAL PLANNER
(CFP®) certification is
�
ied Financial Planner Board of Standards Inc. to individuals who meet education, examination,
awarded by the Certi
experience and ethics requirements. Educational requirements include completing a set of courses on
inancial
planning or, alternatively, previously achieved certain designations such as a CPA or attorney. Currently, applicants
must also pass a ten-hour examination, have at least three years of qualifying work experience in the profession, and
must agree to adhere to a Code of Ethics. Every two years, all CFP® practitioners must meet re-accreditation
requirements by obtaining 30 hours of continuing education credits, including two hours of ethics training.
Certi�ied Divorce Financial Analyst® (CDFA™).
�
�
A Certi
ied Divorce Financial Analyst® (CDFA™) is someone who
�
inancial planning, accounting or legal background and goes through an intensive training program to
TM
�
inancial issues of divorce. The role of the CDFA
�
comes from a
become skilled in analyzing and providing expertise related to the
inancial decisions made today will impact the
professional is to help both the client and lawyer understand how the
client’s
inancial future, based on certain assumptions. All CDFA professionals adhere to a Code of Ethics and are
required to renew their designation every two years by completing 15 hours of continuing education,
reaffirming their adherence to the CDFATM Professional Practice Standards.
3
�
Accredited Investment Fiduciary (AIF®).
�
The Accredited Investment Fiduciary (AIF®) certi
�
�
�
�
�
ication is administered by the Center for Fiduciary Studies, LLC (a Fiduciary360 (
i360) company).
ies that the recipient
iduciary standards of care, their application to the investment management process,
has advanced knowledge of
and procedures for assessing conformance by third parties to
iduciary standards. To be eligible to receive the AIFA
designation, individuals must have already completed the AIF training program and passed the AIF exam and meet
a minimum prerequisite score based on the candidate’s educational background and professional training and
�
inancial services and auditing. To receive the AIFA designation, individuals must complete
experience in investing,
a training program, successfully pass a comprehensive, closed-book
inal examination under the supervision of a
proctor and agree to abide by the AIFA Code of Ethics. In order to maintain the AIFA designation, the individual must
annually renew their af
irmation of the AIFA Code of Ethics and complete ten hours of continuing education credits.
The certi
Accredited Domestic Partnership AdvisorSM (ADPA®).
SM
®
�
(ADPA
�
Individuals who hold the Accredited Domestic Partnership
) designation have completed a course of study encompassing wealth transfers, federal taxation,
Advisor
retirement planning, and planning for
inancial and medical end-of-life needs for domestic partners. Additionally,
individuals must pass an end-of-course examination that tests their ability to synthesize complex concepts and apply
theoretical concepts to real-life situations. All designees have agreed to adhere to Standards of Professional Conduct
and are subject to a disciplinary process. Designees renew their designation every two-years by completing 16 hours
of continuing education, reaf
irming adherence to the Standards of Professional Conduct and complying with self-
disclosure requirements.
ITEM 3. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of each supervised person providing investment advice. There is NO
applicable information to disclose about Michael Creamer.
Other public information on Michael Creamer is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 4. OTHER BUSINESS ACTIVITIES
Michael Creamer does not engage in outside business activities.
ITEM 5. ADDITIONAL COMPENSATION
Michael Creamer does not receive any economic benefit from any person, company, or organization, other than
Glass Jacobson in exchange for providing clients advisory services through Glass Jacobson.
ITEM 6. SUPERVISION
�
icer of Glass Jacobson, who con
Mr. Creamer’s advisory activities are supervised by the Managing Members of the Company, Michael Cohen,
Jonathan Dinkins and Edward Jacobson. Each of Messrs. Cohen, Dinkins and Jacobson can be reached at 443-384-
6888. Mr. Creamer may recommend to clients only those securities and other investments that are included on the
�
Company’s current list of “approved” investments. Thus, his advice and recommendations to clients are monitored
by an administrative of
irms that trades placed for client accounts are limited to
securities appearing on such “approved” list.
4
Jonathan S. Dinkins
Glass Jacobson Investment Advisors, LLC 10055 Red Run Boulevard, Suite 160 Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
�
www.adviserinfo.sec.gov
This brochure supplement provides information about Jonathan S. Dinkins, and supplements the information
contained in the brochure of Glass Jacobson Investment Advisors, LLC (“Glass Jacobson” or the “Company”). You
should have received a copy of that brochure. Please contact Jonathan Dinkins, Chief Compliance Of
icer of Glass
Jacobson, if you did not receive Glass Jacobson’s brochure or if you have any questions about the contents of this
.
supplement. Additional information about Mr. Dinkins is available on the SEC’s website at
ITEM 2. EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Mr. Dinkins graduated with a B.B.A. in Accounting from Marshall University in 1977. He currently holds the
following professional designations: CPA/PFS, CIMA®.
Mr. Dinkins was born in 1955 and joined Glass Jacobson in 2002 as an investment advisor representative. He has
been a Managing Member of the Company since 2004. He holds a dual registration with Mercer Global Advisors,
Inc., as Principal, Sr. Wealth Advisor, joining Mercer in December 2025.
Certi�ied Public Accountant (CPA).
�
�
Code of Professional Conduct
�
�
�
licts of interest (and obtain client consent if a con
identiality, disclose to the client any commission or referral fees, and serve the public interest when providing
CPAs are licensed and regulated by their state boards of accountancy. While
state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally
include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a
concentration in accounting), minimum experience levels (most states require at least one year of experience
providing services that involve the use of accounting, attest, compilation, management advisory,
inancial advisory,
tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful
passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion
of 40 hours of continuing professional education (CPE) each year (or 80 hours over a two year period or 120 hours
over a three year period). Additionally, all American Institute of Certi
ied Public Accountants (AICPA) members are
which requires that they act with integrity, objectivity, due
required to follow a rigorous
care, competence, fully disclose any con
lict exists), maintain client
�
Code of Professional
con
Conduct
inancial services. The vast majority of state boards of accountancy have adopted the AICPA’s
within their state accountancy laws or have created their own.
Personal Financial Specialist (PFS).
�
�
inancial planning business experience, complete 80 hours of personal
�
inancial planning CPE credits every three years. The PFS credential is administered through the AICPA.
�
The PFS credential demonstrates that an individual has met the minimum
education, experience and testing required of a CPA in addition to a minimum level of expertise in personal
inancial
�
�
planning. To attain the PFS credential, a candidate must hold an unrevoked CPA license, fulfill 3,000 hours of personal
inancial planning CPE credits, pass a
comprehensive
inancial planning exam and be an active member of the AICPA. A PFS credential holder is required
to adhere to the AICPA’s Code of Professional Conduct, and is encouraged to follow the AICPA’s Statement on
Responsibilities in Financial Planning Practice. To maintain their PFS credential, the recipient must complete 60
hours of
Certi�ied Investment Management Analyst (CIMA®).
�
�
The Certi
ication signi
�
�
�
�
ication are three years of
ication, candidates must pass an online Quali
�
�
ication.
ied Investment Management Analyst (CIMA®)
certi
ies that an individual has met initial and on-going experience, ethical, education, and examination
requirements for investment management consulting, including advanced investment management theory and
inancial services experience and an
application. Prerequisites for the CIMA® certi
ication
acceptable regulatory history. To obtain the CIMA® certi
Examination, successfully complete a one-week classroom education program provided by a Registered Education
Provider at an AACSB accredited university business school, and pass an online Certi
ication Examination. CIMA®
designees are required to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and
Guidelines for Use of the Marks. CIMA® designees must report 40 hours of continuing education credits, including
two ethics hours, every two years to maintain the certi
5
ITEM 3. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of each supervised person providing investment advice. There is NO
applicable information to disclose about Jonathan Dinkins.
Other public information on Jonathan Dinkins.is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 4. OTHER BUSINESS ACTIVITIES
Jonathan Dinkins does engage in outside business activities.
•12/2024, Owner Operator, Rental Property
Duties include: Coordinate outsourced service providers, keep accounting records, and pay bills. This outside business activity
is investment-related. Jonathan Dinkins dedicates 1-2 hour(s) a month to this outside business activity.
Glass Jacobsons’ clients are never obligated or required to purchase products, services, or engage with advisors’ outside
business activities.
TEM 5. ADDITIONAL COMPENSATION
Jonathan Dinkins does not receive any economic benefit from any person, company, or organization, other than
Glass Jacobson in exchange for providing clients advisory services through Glass Jacobson.
ITEM 6. SUPERVISION
�
icer of Glass Jacobson, who con
As a Managing Member of Glass Jacobson, Mr. Dinkins’ activities are supervised by other Managing Members of the
Company, Michael Cohen and Edward Jacobson. Each of Messrs. Cohen and Jacobson can be reached at 443-384-
6888. Mr. Dinkins recommends to clients only those securities and other investments that are included on the
�
Company’s current list of “approved” investments. Thus, his advice and recommendations to clients are monitored
by an administrative of
irms that trades placed for client accounts are limited to
securities appearing on such “approved” list.
6
George Thomas (“Trey”) Ingram III
Glass Jacobson Investment Advisors, LLC 10055 Red Run Boulevard, Suite 160 Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
�
www.adviserinfo.sec.gov
This brochure supplement provides information about Trey Ingram, and supplements the information contained in
the brochure of Glass Jacobson Investment Advisors, LLC (“Glass Jacobson” or the “Company”). You should have
received a copy of that brochure. Please contact Jonathan Dinkins, Chief Compliance Of
icer of Glass Jacobson, if you
did not receive Glass Jacobson’s brochure or if you have any questions about the contents of this supplement.
Additional information about Mr. Ingram is available on the SEC’s website at
.
ITEM 2. EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Mr. Ingram graduated with a Masters of Business Administration from the George Washington University in 2011
and a B.S. in Finance from the University of North Carolina at Wilmington in 2001. Mr. Ingram holds the following
professional designations: CFP® and (CAIA®).
TM
Mr. Ingram was born in 1979 and joined Glass Jacobson as an investment advisor representative in 2019. He holds
a dual registration with Mercer Global Advisors, Inc., as Wealth Advisor, joining Mercer in December 2025.
CERTIFIED FINANCIAL PLANNERTM (CFP®).
�
The CERTIFIED FINANCIAL PLANNER
(CFP®) certification is
�
ied Financial Planner Board of Standards Inc. to individuals who meet education, examination,
awarded by the Certi
inancial
experience, and ethics requirements. Educational requirements include completing a set of courses on
planning or, alternatively, previously achieved certain designations such as a CPA or attorney. Currently, applicants
must also pass a ten-hour examination, have at least three years of qualifying work experience in the profession, and
must agree to adhere to a Code of Ethics. Every two years, all CFP® practitioners must meet re- accreditation
requirements by obtaining 30 hours of continuing education credits, including two hours of ethics training.
Certi�ied Alternative Investment Analyst (CAIA
�
®): The Chartered Alternative Investment Analyst (CAIA®) is a
professional designation granted by the Chartered Alternative Investment Analyst Association to candidates who
have completed Level I and Level II examinations. The Chartered Alternative Investment Analyst Association has
established the designation of CAIA to certify that the holders have met the association’s educational standard for
specialists in alternative investments. The alternative investments that a Chartered Alternative Investment Analyst
is trained to assess include hedge funds, venture capital, private equity, funds of funds, derivatives and real estate
investments. In order to receive the designation, individuals must have at least one year of professional experience
and a U.S. bachelor's degree and must pass a two-level curriculum that includes topics ranging from qualitative
analysis and trading theories of alternative investment to indexation and benchmarking . Once certi
ied, there are
annual membership dues and the designee completes a self-evaluation tool every three years to maintain the
designation.
ITEM 3. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of each supervised person providing investment advice. There is NO
applicable information to disclose about George Ingram III.
Other public information on George Ingram III is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 4. OTHER BUSINESS ACTIVITIES
George Ingram III does engage in outside business activities.
•06/2000, Owner, Rental Properties
Duties include: Own two rental properties that are managed by a professional property manager. This outside
business activity is investment-related. George Ingram III dedicates less than 1 hour(s) a month to this outside
7
business activity.
Glass Jacobsons’ clients are never obligated or required to purchase products, services, or engage with advisors’ outside
business activities.
ITEM 5. ADDITIONAL COMPENSATION
George Ingram III does not receive any economic benefit from any person, company, or organization, other than
Glass Jacobson in exchange for providing clients advisory services through Glass Jacobson.
ITEM 6. SUPERVISION
�
�
icer of Glass Jacobson, who con
Mr. Ingram’s advisory activities are supervised by the Managing Members of the Company, Michael Cohen, Jonathan
Dinkins and Edward Jacobson. Each of Messrs. Cohen, Dinkins and Jacobson can be reached at 443-384-6888. Mr.
Ingram may recommend to clients only those securities and other investments that are included on the Company’s
current list of “approved” investments. Thus, his advice and recommendations to clients are monitored by an
administrative of
irms that trades placed for client accounts are limited to securities
appearing on such “approved” list.
8
Joseph T. McCarthy
Glass Jacobson Investment Advisors, LLC 10055 Red Run Boulevard, Suite 160 Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
�
www.adviserinfo.sec.gov
This brochure supplement provides information about Joseph T. McCarthy, and supplements the information contained
in the brochure of Glass Jacobson Investment Advisors, LLC (“Glass Jacobson” or the “Company”). You should have
received a copy of that brochure. Please contact Jonathan Dinkins, Chief Compliance Of
icer of Glass Jacobson, if you did
not receive Glass Jacobson’s brochure or if you have any questions about the contents of this supplement. Additional
information about Mr. McCarthy is available on the SEC’s website at
.
ITEM 2. EDUCATIONAL BACKGROUND
AND BUSINESS EXPERIENCE
He received a B.S. in Finance from Salisbury University in 2013. Mr. McCarthy holds the following professional
designations: CFP®, ChFC®
�
TM
Mr. McCarthy was born in 1991 and joined Glass Jacobson in 2023 as a Senior Wealth Advisor. He holds a dual
registration with Mercer Global Advisors, Inc., as Wealth Advisor, joining Mercer in December 2025. Mr. McCarthy
was previously employed by Edelman Financial Engines from 2016 to 2019. He then transitioned to UBS in 2020
until 2023.
CERTIFIED FINANCIAL PLANNERTM (CFP®).
�
The CERTIFIED FINANCIAL PLANNER
(CFP®) certi
ication is
�
ied Financial Planner Board of Standards Inc. to individuals who meet education, examination,
awarded by the Certi
experience and ethics requirements. Educational requirements include completing a set of courses on
inancial
planning or, alternatively, previously achieved certain designations such as a CPA or attorney. Currently, applicants
must also pass a ten-hour examination, have at least three years of qualifying work experience in the profession, and
must agree to adhere to a Code of Ethics. Every two years, all CFP® practitioners must meet re-accreditation
requirements by obtaining 30 hours of continuing education credits, including two hours of ethics training.
CHARTERED FINANCIAL CONSULTANT® (ChFC®)
�
The CHARTERED FINANCIAL CONSULTANT® (ChFC®)
�
ication is awarded by the American College of Financial Services to individuals who meet education, examination,
certi
experience and ethics requirements. Educational requirements include completing a set of courses on
inancial
planning or, alternatively, previously achieved certain designations such as a CFP. Currently, applicants must have at
least three years of qualifying work experience in the profession and must agree to adhere to a Code of Ethics. Every
two years, all ChFC® practitioners must meet re-accreditation requirements by obtaining 30 hours of continuing
education credits, including two hours of ethics training.
ITEM 3. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of each supervised person providing investment advice. There IS
applicable information to disclose about Joseph McCarthy.
Other public information on Joseph McCarthy is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 4. OTHER BUSINESS ACTIVITIES
Joseph McCarthy does not engage in outside business activities.
.
ITEM 5. ADDITIONAL COMPENSATION
Joseph McCarthy does not receive any economic benefit from any person, company, or organization, other than Glass
Jacobson in exchange for providing clients advisory services through Glass Jacobson.
9
ITEM 6. SUPERVISION
�
�
icer of Glass Jacobson, who con
Mr. McCarthy’s advisory activities are supervised by the Managing Members of the Company, Michael Cohen,
JonathanDinkins and Edward Jacobson. Each of Messrs. Cohen, Dinkins and Jacobson can be reached at 443-384-
6888. Mr. McCarthy may recommend to clients only those securities and other investments that are included on
the Company’s current list of “approved” investments. Thus, his advice and recommendations to clients are
irms that trades placed for client accounts are
monitored by an administrative of
limited to securities appearing on such “approved” list.
10
Todd C. Norris
Glass Jacobson Investment Advisors, LLC 10055 Red Run Boulevard, Suite 160 Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
�
www.adviserinfo.sec.gov
This brochure supplement provides information about Todd Norris, and supplements the information contained in
the brochure of Glass Jacobson Investment Advisors, LLC (“Glass Jacobson” or the “Company”). You should have
received a copy of that brochure. Please contact Jonathan Dinkins, Chief Compliance Of
icer of Glass Jacobson, if you
did not receive Glass Jacobson’s brochure or if you have any questions about the contents of this supplement.
Additional information about Mr. Norris is available on the SEC’s website at
.
ITEM 2. EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
He received a B.S. in Finance from the University of Maryland in 2007. Mr. Norris holds the following professional
designations: CFP®
TM
Mr. Norris was born in 1984 and joined Glass Jacobson in 2020 as an investment advisor representative. He holds a
dual registration with Mercer Global Advisors, Inc., as Sr. Wealth Advisor, joining Mercer in December 2025.
CERTIFIED FINANCIAL PLANNERTM (CFP®).
�
The CERTIFIED FINANCIAL PLANNER
(CFP®) certification is
�
ied Financial Planner Board of Standards Inc. to individuals who meet education, examination,
awarded by the Certi
experience, and ethics requirements. Educational requirements include completing a set of courses on
inancial
planning or, alternatively, previously achieved certain designations such as a CPA or attorney. Currently, applicants
must also pass a ten-hour examination, have at least three years of qualifying work experience in the profession, and
must agree to adhere to a Code of Ethics. Every two years, all CFP® practitioners must meet re- accreditation
requirements by obtaining 30 hours of continuing education credits, including two hours of ethics training.
ITEM 3. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that
would be material to your evaluation of each supervised person providing investment advice. There is NO applicable
information to disclose about Todd Norris.
Other public information on Todd Norris is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 4. OTHER BUSINESS ACTIVITIES
Todd Norris does not engage in outside business activities.
ITEM 5. ADDITIONAL COMPENSATION
Todd Norris does not receive any economic benefit from any person, company, or organization, other than Glass
Jacobson in exchange for providing clients advisory services through Glass Jacobson.
ITEM 6. SUPERVISION
�
�
icer of Glass Jacobson, who con
Mr. Norris’s advisory activities are supervised by the Managing Members of the Company, Michael Cohen, Jonathan
Dinkins and Edward Jacobson. Each of Messrs. Cohen, Dinkins and Jacobson can be reached at 443-384-6888. Mr.
Norris may recommend to clients only those securities and other investments that are included on the Company’s
current list of “approved” investments. Thus, his advice and recommendations to clients are monitored by an
irms that trades placed for client accounts are limited to securities
administrative of
appearing on such “approved” list.
11
Dovid Price
Glass Jacobson Investment Advisors, LLC 10055 Red Run Boulevard, Suite 160 Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
�
www.adviserinfo.sec.gov
This brochure supplement provides information about Dovid Price, and supplements the information contained in
the brochure of Glass Jacobson Investment Advisors, LLC (“Glass Jacobson” or the “Company”). You should have
received a copy of that brochure. Please contact Jonathan Dinkins, Chief Compliance Of
icer of Glass Jacobson, if you
did not receive Glass Jacobson’s brochure or if you have any questions about the contents of this supplement.
Additional information about Mr. Price is available on the SEC’s website at
.
ITEM 2. EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
�
TM
�
Prior to entering the
inancial services industry, he held a paid fellowship in advanced Talmudic studies at Yeshiva
Birchas Mordechai (2013-2016, 2017-2019) and Aish HaTorah (2017). He received a Bachelors in Talmudic Law
(CFP®) and Wealth
from the Ner Israel College in 2013. He holds the CERTIFIED FINANCIAL PLANNER
Management Specialist™ or WMS™ Professional Designations and has passed the Certi
ied Investment
Management Analyst (CIMA®).
�
�
�
irm DP Financial in 2020. He has worked as a
TM
Mr. Price was born in 1988 and joined Glass Jacobson in 2021 as an investment advisor representative. He holds a
dual registration with Mercer Global Advisors, Inc., as Sr. Wealth Advisor, joining Mercer in December 2025. Prior
to working at Glass Jacobson, he founded his
inance instructor from
2020-2021, as a
inancial planning intern with Shober & Zelcer Financial Planning and Management in 2020, as an
LPL advisor with Cross Country Wealth from 2019-2020 and served a tax internship in 2018.
CERTIFIED FINANCIAL PLANNERTM (CFP®).
�
The CERTIFIED FINANCIAL PLANNER
(CFP®) certification is
�
�
ied Financial Planner Board of Standards Inc. to individuals who meet education, examination,
awarded by the Certi
inancial
experience, and ethics requirements. Educational requirements include completing a set of courses on
planning or, alternatively, previously achieved certain designations such as a CPA or attorney. Currently, applicants
must also pass a ten-hour examination, have at least three years of qualifying work experience in the profession, and
must agree to adhere to a Code of Ethics. Every two years, all CFP® practitioners must meet re- accreditation
requirements by obtaining 30 hours of continuing education credits, including two hours of ethics training.
Certi�ied Investment Management Analyst (CIMA®).
�
�
The Certi
ication signi
�
�
�
�
ication are three years of
ication, candidates must pass an online Quali
�
�
ication.
ied Investment Management Analyst (CIMA®)
certi
ies that an individual has met initial and on-going experience, ethical, education, and examination
requirements for investment management consulting, including advanced investment management theory and
inancial services experience and an
application. Prerequisites for the CIMA® certi
acceptable regulatory history. To obtain the CIMA® certi
ication
Examination, successfully complete a one-week classroom education program provided by a Registered Education
Provider at an AACSB accredited university business school, and pass an online Certi
ication Examination. CIMA®
designees are required to adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and
Guidelines for Use of the Marks. CIMA® designees must report 40 hours of continuing education credits, including
two ethics hours, every two years to maintain the certi
Wealth Management Specialist™ or WMS™:
Individuals who hold the WMS™ designation have completed a course
of study encompassing risk management, investments, insurance, tax, retirement, and estate planning issues.
Additionally, individuals must pass an end-of-course examination that tests their knowledge of these topics. All
designees must adhere to standards of professional conduct and complete 16 hours of continued education every
two years.
ITEM 3. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of each supervised person providing investment advice. There is NO
12
applicable information to disclose about Dovid Price.
Other public information on Dovid Price is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 4. OTHER BUSINESS ACTIVITIES
Dovid Price does engage in outside business activities.
•01/2024, Financial Manager, Esther Price, CCC-SLP
Duties include: Assist with preparing billing, technology, bookkeeping, and preparing for taxes. This outside
business activity is not investment-related. Dovid Price dedicates 20 hour(s) a month to this outside business
activity.
Glass Jacobsons’ clients are never obligated or required to purchase products, services, or engage with advisors’
outside business activities.
ITEM 5. ADDITIONAL COMPENSATION
Dovid Price does not receive any economic benefit from any person, company, or organization, other than Glass
Jacobson in exchange for providing clients advisory services through Glass Jacobson.
ITEM 6. SUPERVISION
�
�
icer of Glass Jacobson, who con
irms that trades placed for client accounts are limited to securities appearing on such
Mr. Price’s activities are supervised by the Managing Members of the Company, Michael Cohen, Jonathan Dinkins
and Edward Jacobson. Each of Messrs. Cohen, Dinkins and Jacobson can be reached at 443-384-6888. Mr. Price may
recommend to clients only those securities and other investments that are included on the Company’s current list of
“approved” investments. Thus, his advice and recommendations to clients are monitored by an administrative
of
“approved” list.
13
Richard J. Osikowicz
Glass Jacobson Investment Advisors, LLC 10055 Red Run Boulevard, Suite 160 Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
�
www.adviserinfo.sec.gov
.
This brochure supplement provides information about Richard Osikowicz, and supplements the information
contained in the brochure of Glass Jacobson Investment Advisors, LLC (“Glass Jacobson” or the “Company”). You
should have received a copy of that brochure. Please contact Jonathan Dinkins, Chief Compliance Of
icer of Glass
Jacobson, if you did not receive Glass Jacobson’s brochure or if you have any questions about the contents of this
supplement. Additional information about Mr. Osikowicz is available on the SEC’s website at
ITEM 2. EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
He graduated with a B.S. from the Towson University in 1994. Mr. Osikowicz holds the following professional
designations: CFP®,AIF®, CEPA®.
TM
Mr. Osikowicz was born in 1971 and joined Glass Jacobson as an investment advisor representative in 2018. He
holds a dual registration with Mercer Global Advisors, Inc., as Sr. Wealth Advisor, joining Mercer in December
CERTIFIED FINANCIAL PLANNERTM (CFP®).
2025.
�
The CERTIFIED FINANCIAL PLANNER
(CFP®) certification is
�
�
awarded by the Certi
ied Financial Planner Board of Standards Inc. to individuals who meet education, examination,
inancial
experience and ethics requirements. Educational requirements include completing a set of courses on
planning or, alternatively, previously achieved certain designations such as a CPA or attorney. Currently, applicants
must also pass a ten-hour examination, have at least three years of qualifying work experience in the profession, and
must agree to adhere to a Code of Ethics. Every two years, all CFP® practitioners must meet re-accreditation
requirements by obtaining 30 hours of continuing education credits, including two hours of ethics training.
Accredited Investment Fiduciary (AIF®).
�
The Accredited Investment Fiduciary (AIF®) certi
�
�
�
�
�
ies that the recipient
iduciary standards of care, their application to the investment management process,
has advanced knowledge of
iduciary standards. To be eligible to receive the AIFA
and procedures for assessing conformance by third parties to
designation, individuals must have already completed the AIF training program and passed the AIF exam and meet
a minimum prerequisite score based on the candidate’s educational background and professional training and
�
inancial services and auditing. To receive the AIFA designation, individuals must complete
experience in investing,
inal examination under the supervision of a
a training program, successfully pass a comprehensive, closed-book
proctor and agree to abide by the AIFA Code of Ethics. In order to maintain the AIFA designation, the individual must
annually renew their af
irmation of the AIFA Code of Ethics and complete ten hours of continuing education credits.
The certi
ication is administered by the Center for Fiduciary Studies, LLC (a Fiduciary360 (
i360) company).
ITEM 3. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of each supervised person providing investment advice. There is NO
applicable information to disclose about Richard Osikowicz.
Other public information on Richard Osikowicz is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 4. OTHER BUSINESS ACTIVITIES
Richard Osikowicz does engage in outside business activities.
•1/1/2008, Sole Proprietor/Photographer, Photographs by Rich
Duties include: Offer photography services - head shots, family portraits, event photography (sports, theater), and
sell images online. This outside business activity is not investment-related. Richard Osikowicz dedicates 1-2
14
hour(s) a month to this outside business activity.
Glass Jacobsons’ clients are never obligated or required to purchase products, services, or engage with advisors’
outside business activities.
ITEM 5. ADDITIONAL COMPENSATION
Richard Osikowicz does not receive any economic benefit from any person, company, or organization, other than Glass
Jacobson in exchange for providing clients advisory services through Glass Jacobson.
ITEM 6. SUPERVISION
�
icer of Glass Jacobson, who con
Mr. Osikowicz advisory activities are supervised by the Managing Members of the Company, Michael Cohen,
Jonathan Dinkins and Edward Jacobson. Each of Messrs. Cohen, Dinkins and Jacobson can be reached at 443-384-
6888. Mr. Osikowicz may recommend to clients only those securities and other investments that are included on the
�
Company’s current list of “approved” investments. Thus, his advice and recommendations to clients are monitored
by an administrative of
irms that trades placed for client accounts are limited to
securities appearing on such “approved” list.
15
George R. Toulson
Glass Jacobson Investment Advisors, LLC 10055 Red Run Boulevard, Suite 160 Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
�
www.adviserinfo.sec.gov
This brochure supplement provides information about George Toulson and supplements the information contained
in the brochure of Glass Jacobson Investment Advisors, LLC (“Glass Jacobson” or the “Company”). You should have
received a copy of that brochure. Please contact Jonathan Dinkins, Chief Compliance Of
icer of Glass Jacobson, if you
did not receive Glass Jacobson’s brochure or if you have any questions about the contents of this supplement.
Additional information about Mr. Toulson is available on the SEC’s website at
.
ITEM 2. EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
�
ied
He received a B.A. in Economics from Yale University in 1994, and is a Chartered Financial Analyst, and Certi
Financial Planner®. Mr. Toulson holds the following professional designations: CFA®, CFP®
Mr. Toulson was born in 1972 and joined Glass Jacobson in 2021 as an investment advisor representative. He
holds a dual registration with Mercer Global Advisors, Inc., as Sr. Wealth Advisor, joining Mercer in December
2025. Since 2019 he worked as a Private Wealth Advisor at Wick Capital Partners.
A Chartered Financial Analyst (CFA®)
�
�
charter is a designation given to those who have completed the CFA®
Program and completed acceptable work experience requirements. The CFA Program is a three-part exam that tests
the fundamentals of investment tools, valuing assets, portfolio management, and wealth planning. The CFA Program
inance, accounting, economics, or business. CFA charterholders
is typically completed by those with backgrounds in
earn the right to use the CFA designation after program completion, application, and acceptance by CFA Institute.
CFA charterholders are quali
ied to work in senior and executive positions in investment management, risk
management, asset management, and more.
CERTIFIED FINANCIAL PLANNERTM (CFP®).
�
The CERTIFIED FINANCIAL PLANNERTM (CFP®) certification is
�
ITEM 3. DISCIPLINARY INFORMATION
awarded by the Certi
ied Financial Planner Board of Standards Inc. to individuals who meet education,
examination, experience, and ethics requirements. Educational requirements include completing a set of courses
inancial planning or, alternatively, previously achieved certain designations such as a CPA or attorney.
on
Currently, applicants must also pass a ten-hour examination, have at least three years of qualifying work
experience in the profession, and must agree to adhere to a Code of Ethics. Every two years, all CFP® practitioners
must meet re-accreditation requirements by obtaining 30 hours of continuing education credits, including two
hours of ethics training.
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of each supervised person providing investment advice. There is NO
applicable information to disclose about George Toulson.
Other public information on George Toulson is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 4. OTHER BUSINESS ACTIVITIES
George Toulson does engage in outside business activities.
�
�
Mr. Toulson holds a minority membership interest in UNLTD Sports Group LLC, a Delaware limited liability company
that provides sports management, representation, and marketing to professional athletes (“UNLTD”). Mr. Toulson
does not actively participate in the management of UNLTD. To eliminate any potential con
lict that could arise
between Mr. Toulson’s association with the Company and his membership interest UNLTD, the Company has
prohibited Mr. Toulson and all its investment adviser representatives from recommending investment in UNLTD. As
Mr. Toulson has maintained a close working relationship with the principals of UNLTD, UNLTD may refer its clients
licts, neither Mr. Toulson nor
to Mr. Toulson for investment advisory services. In such cases, to avoid potential con
16
the Company will compensate UNLTD for these referrals. Any UNLTD clients referred to Mr. Toulson for investment
�
advisory services are under no obligation to accept investment advisory services from Mr. Toulson or any other
investment adviser representative of the Company. Additionally, to any client of UNLTD that is referred to Mr.
Toulson, Mr. Toulson will disclose in writing that he holds a minority membership interest in UNLTD. The Company
lict related to UNLTD referring its clients to Mr. Toulson for investment advisory
believes that any potential con
services is addressed by this manner of disclosure in this brochure supplement.
�
�
Mr. Toulson also holds minority membership interests in DB Game, LLC (“DB Game”) and DB Game II, LLC (“DB Game
II”), each a Delaware limited liability company. DB Game and DB Game II were formed for the sole purpose of
investing in the preferred stock of HiDef Inc., a Nevada corporation (“HiDef”). HiDef, formerly DanceBattle, Inc., is a
media, entertainment and technology company focused on creating and delivering state-of-the-art video game
content experiences across all digital platforms to consumers primarily in North America and the European Union.
Mr. Toulson is the managing member of both DB Game and DB Game II. As managing member, Mr. Toulson does
actively participate in the management of either company. DB Game is available to investors as a private offering. To
eliminate any potential con
licts that could arise between Mr. Toulson’s association with the Company and his
membership in interest in DB Game and DB Game II, as well as his indirect investment in HiDef, the Company has
prohibited all its investment adviser representatives, including Mr. Toulson, from recommending to the Company’s
clients that they invest in DB Game, DB Game II, and/or HiDef. In circumstances where an individual has, prior to
becoming a client of the Company, invested in DB Game, DB Game II, or HiDef, the investment adviser representatives
of the Company, including Mr. Toulson, are required to disclose in writing Mr. Toulson’s relationship with these
entities, as applicable, before providing any investment advice relating to any of the entities. The Company believes
lict of interest related to DB Game, LLC and DB Game II, and Mr. Toulson is addressed by this
that any potential con
manner of disclosure in this brochure supplement.
Glass Jacobsons’ clients are never obligated or required to purchase products, services, or engage with advisors’
outside business activities
ITEM 5. ADDITIONAL COMPENSATION
George Toulson does not receive any economic benefit from any person, company, or organization, other than Glass
Jacobson in exchange for providing clients advisory services through Glass Jacobson.
ITEM 6. SUPERVISION
�
icer of Glass Jacobson, who con
irms that trades placed for client accounts are limited to
Mr. Toulson’s advisory activities are supervised by the Managing Members of the Company, Michael Cohen,
Jonathan Dinkins and Edward Jacobson. Each of Messrs. Cohen, Dinkins and Jacobson can be reached at 443-384-
6888. Mr. Toulson may recommend to clients only those securities and other investments that are included on the
�
Company’s current list of “approved” investments. Thus, his advice and recommendations to clients are monitored
by an administrative of
securities appearing on such “approved” list.
17
Marina Sidelnikova
Glass Jacobson Investment Advisors, LLC 10055 Red Run Boulevard, Suite 160 Owings Mills, MD 21117
443-384-6888
www.glassjacobson.com
March 11, 2026
�
www.adviserinfo.sec.gov
This brochure supplement provides information about Marina Sidelnikova, and supplements the information
contained in the brochure of Glass Jacobson Investment Advisors, LLC (“Glass Jacobson” or the “Company”). You
should have received a copy of that brochure. Please contact Jonathan Dinkins, Chief Compliance Of
icer of Glass
Jacobson, if you did not receive Glass Jacobson’s brochure or if you have any questions about the contents of this
.
supplement. Additional information about Ms. Sidelnikova is available on the SEC’s website at
ITEM 2. EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
She graduated with a M.S. in Physics from Kishinev State University in 1984, and earned her MBA from Loyola
College of Maryland in 2007. Ms. Sidelnikova currently holds the following professional designation: CPWA® and
AIF®.
�
SM
Ms. Sidelnikova was born in 1961 and joined Glass Jacobson as an investment advisor representative in 2007. S h e
holds a dual registration with Mercer Global Advisors, Inc., as Sr. Wealth Advisor, joining Mercer in December
2025.
Certi�ied Private Wealth AdvisorSM (CPWA®).
�
The Certi
ied Private Wealth Advisor
�
�
�
ication are a full
�
�
�
ication.
�
(CPWA®) is an advanced
ically for wealth managers and advisors who work with high-net-worth clients on the life
credential created speci
ive
cycle of wealth: accumulation, preservation, and distribution. Prerequisites for CPWA certi
inancial services or a related industry, Bachelor’s degree from
years of professional client-centered experience in
an accredited college or University and an acceptable regulatory history. To obtain the CPWA certi
ication,
candidates must complete 6 months of pre-study education and online quizzes, successfully complete a 5-day in
inal CPWA exam. CPWA designees are required to adhere to the Investment
class program and pass the
Management Consultants Association’s code of Professional Responsibility, Standards of Practice, and Rules and
Guidelines for Use of the Marks. CPWA designees must report 40 hours of continuing education credits, including
two ethics hours, every two years to maintain the certi
Accredited Investment Fiduciary (AIF®).
�
The Accredited Investment Fiduciary (AIF®) certi
�
�
�
�
�
ies that the recipient
iduciary standards of care, their application to the investment management process,
has advanced knowledge of
and procedures for assessing conformance by third parties to
iduciary standards. To be eligible to receive the AIFA
designation, individuals must have already completed the AIF training program and passed the AIF exam and meet
a minimum prerequisite score based on the candidate’s educational background and professional training and
�
inancial services and auditing. To receive the AIFA designation, individuals must complete
experience in investing,
a training program, successfully pass a comprehensive, closed-book
inal examination under the supervision of a
proctor and agree to abide by the AIFA Code of Ethics. In order to maintain the AIFA designation, the individual must
irmation of the AIFA Code of Ethics and complete ten hours of continuing education credits.
annually renew their af
The certi
ication is administered by the Center for Fiduciary Studies, LLC (a Fiduciary360 (
i360) company).
ITEM 3. DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events
that would be material to your evaluation of each supervised person providing investment advice. There is NO
applicable information to disclose about Marina Sidelnikova.
Other public information on Marina Sidelnikova is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 4. OTHER BUSINESS ACTIVITIES
Marina Sidelnikova does engage in outside business activities.
18
•6/1/2007, Landlord, Rental Property A
Duties include: Collect rent, pay bills, and update lease annually. This outside business activity is investment-
related. Marina Sidelnikova dedicates less than 1 hour(s) a month to this outside business activity.
•9/1/2001, Landlord, Rental Property B
Duties include: Collect rent, pay bills, and update lease annually. This outside business activity is investment-
related. Marina Sidelnikova dedicates less than 1 hour(s) a month to this outside business activity.
Glass Jacobsons’ clients are never obligated or required to purchase products, services, or engage with advisors’
outside business activities.
ITEM 5. ADDITIONAL COMPENSATION
Marina Sidelnikova does not receive any economic benefit from any person, company, or organization, other than Glass
Jacobson in exchange for providing clients advisory services through Glass Jacobson.
ITEM 6. SUPERVISION
�
�
icer of Glass Jacobson, who con
Ms. Sidelnikova’s activities are supervised by the Managing Members of the Company, Michael Cohen,
JonathanDinkins and Edward Jacobson. Each of Messrs. Cohen, Dinkins and Jacobson can be reached at 443-384-6888.
Ms. Sidelnikova may recommend to clients only those securities and other investments that are included on the
Company’s current list of “approved” investments. Thus, her advice and recommendations to clients are monitored by
irms that trades placed for client accounts are limited to
an administrative of
securities appearing on such “approved” list.
19